ML20052E696

Responds to NRC Re Violations Noted in IE Insp Rept 50-373/82-12.Corrective Actions:Rhr Shutdown Cooling Inboard Suction Isolation Valve 1E12-F009 Added to Outage Checklist

ML20052E696
Person / Time
Site:	LaSalle
Issue date:	04/23/1982
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20052E693	List: IR 05000373/1982012 ML20052E696
References
3940N, NUDOCS 8205110358
Download: ML20052E696 (5)

Text

.*

CN Commonwealth Edison

[C ) one First Nati?nal P!sz?, Chicago, llhnois g

7 Address Reply tJ: Post Office Box 767

\\

/ Chicago, Illinois 60690 April 23, 1982 Mr. Jame s G. Keppler, Regional Administrator Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

LaSalle County Station Unit 1 Response to NRC Inspection Report 50-373/82-12 NRC Docket No. 50-373 Reference (a):

R. L. Spessard letter to Cordell Reed dated March 25, 1982

Dear Mr. Keppler:

This letter is in response to the inspection conducted by Messrs. S. E. Shepley,

L. A. Reyes, and N.

Chrissotimos on February 8-26 and March 1-26, 1982 o f activities at LaSalle County Nuclear Station Unit 1.

Reference (a) indicated that certain activities appeared to be in non-compliance with NRC requirements.

The Commonwealth Edison Company response to the notice o f violation is provided in the enclosure.

To the best of my knowledge and belief the statements contained herein and in the enclosure are true and correct.

In some respects, these statements are not based on my personal knowledge 4

but upon information furnished by other Comnionwealth Edison employees.

Such information has been -reviewed in accordance with Company practice and I believe it to be reliable.

If you have any questions fr this matter, please direct them to this office.

Very truly yours, l

L. O. De1Geo rge Director o f Nuclear Licensing Enclosure cc:

NRC Resident Inspector - LSCS SUBSCRIBED and SWORN fo

-before me this a/J g day of

/MlL 1982 b ] 8.

W Foru PashliC G205110358 820503 APR 2 61982 PDR ADOCK 05000373 G

pon

Enclosure Item o f Apparen t Non-Compliance 10 CFR 50, Appendix B, Criterion II, requires in part, that activities af fecting quality be accomplished under suitable controlled conditions, such as adequate cleanliness.

10 CFR 50, Appendix B, Criterion XIII requires, in part, that measures be established to control the storage and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration.

The Quality Assurance Program, Quality Requirement QR2.0, contains Commonwealth Edison Company commitment to the regulatory positions of Regulatory Guide 1.38, Revision 2, and Regulatory Guide 1.39, Revision 2.

The regulatory positions of Regulatory Guides 1.38, Revision 2 and 1.39, Revision 2, endorses the requirements of ANSI N45.2.2-1972 and N45.2.3-1973 respectively.

ANSI N45.2.2-1972, Section 6.2, states, in part, that " Cleanliness and good housekeeping practices shall be enforced at all times in the storage areas.

The storage areas shall be cleaned as required to avoid the accumulation of trash, discarded packaging materials and other detrimental soll:

The use or s torage o f food, drinks...in any storage area shall not be permitted... Periodic inspections shall be performed to assure that storage areas are being maintained."

Section 6.5 states, in part, that " Items released from storage and placed in their final locations within the power plant, shall be... cared for in accordance with the requirements o f Section 6 o f this standard."

ANSI N45.2.3-19 73 requires in part that control of all tools, equipment, materials and supplies be maintained to prevent the inadvertent inclusion of deleterious materials or objects in critical systems.

Contrary to the above, the inspector noted during a plant tour that:

a.

Paper, cigarette butts and a metal table were found inside the 125V and 250V Battery Rooms in the 710 elevation.

b.

Oil soak rags, paper, glass jars and pop cans were found in the 1A, 18, and 0 Emergency Diesel Generator Rooms including the inside of the energized cabinets.

An open paint can was found in the emergency diesel generator c.

cable tray 156AlGP.

Corrective Action and Results Achieved A cleanup crew was alerted to the specific items found in the inspection.

The items were immediately removed.

i i

. i Corrective Action to Avoid Further Non-Compliance A

The. Edison Field Engineer, the Contractor Superintendent in i

charge of painting, the Station Master Electrician and the Technical Staf f Supervisor were informed on the non-compliance and reminded that Battery rooms are not to be used for storage purposes.

A letter signed by the Site Contruction Superintendent was distributed. the day a fter the. identified noncompliance, concerning l

the proper use of flammable liquids.

Those areas still under construction are periodically inspected in accordance with Project Procedure 81-2.

Those areas turned over to the Production. Department are periodically inspected in accordance with the appropriate administrative procedures.

On April 9, 1982, the Project Manager for LaSalle County 1

Station issued a directive to all site personnel.. The pu rpose o f the directive was to inform all personnel that Unit One fuel load was approaching and an individual ef fort by all was required to upgrade the ' mind set' to one of plant operation rather than construction.

One area specifically highlighted in the directive was station housekeeping.

Date of Full Compliance Full compliance has been achieved.

t L

4 1

i L

T

... ~.. -, - -. _.. _ -. -.... _ _, _, _.. -. _, _. -. _. _ -. _. _ _ _ _ _ _. - _ ~, _. - - _,... -... _ - - - - - - - - - - _. _

. Item o f Apparent Noncompliance 10 CFR 50, Appendix B, Criterion XIV, requires measures to be established to indicate the operating status of systems and components, such as by tagging valves, to prevent inadvertent operation.

1 Commonwealth Edison Company Assurance Manual,14-518, Item 3C, states in part:

... attach...out o f service cards at all isolation points, as required by station procedures, to item (or items) taken out o f service."

1 LaSalle County Station Equipment Out o f Service Procedure, LAP 900-4, F.1. f. and Cons truction Ins truction No.1-2-G-1 states the supervisor in charge of the work "has the responsibility to assure that...out o f service cards have been placed correctly and that the equipment is safe to work on."

Contrary to the above, February 17, 1982, the RHR Shutdown Cooling Outboard Isolation Valve IE12-F008 was disassembled with that section of the system not properly tagged out.

This resulted in the discharge of approximately 5,000 gallons o f reactor water 4

into the Reactor Building.

Corrective-Action and Results Achieved The Equipment Outage Checklist for the work on the 1E12-F008 was reviewed following the incident.

The RHR Shutdown Cooling Inboard Suction Isolation Valve 1E12-F009, a necessary isolation point for the work being performed on valve 1E12-F008, was added to the Outage Checklist prior to further work being performed.

l Corrective Action to Avoid Furthe r Non-Compliance i

1.

Shift supervisors have been instructed to accept only written outage requests ( form L AP 900-4, Attachment B) except in emergency.

2.

The Out of Service procedure has been reviewed with the Construction Craf ts, with special emphasis on the following:

a.

Construction Craf ts are not to begin work on a job until specifically instructed to do so by the CECO.

" supervisor in charge of the work" or his designee af ter he has verified proper outage isolation.

b.

Construction Craf ts are not to work on any valves which are tagged as isolation points with an out of service card.

., 3.

This incident was reviewed with the operating-supervisors, nuclear station operators, equipment operators, and_ equipment attendants on all six shif t crews, with emphasis on the f actors contributing to the incident.

4.

A directive was issued by the LaSalle County Station Project Manager to all site personnel concerning

' Conduct of Operations'. 'In the directive all personnel were advised that LaSalle is to be considered an operating plant and identified several areas where a more operationally oriented attitude is required to avoid interface problems.

One of the specific areas emphasized was the Out of Service Procedure.

Date o f Full Compliance

- Full compliance has been achieved for all o f the corrective actions listed above.

3940N i

1